Alaska Packers' Ass'n v. Domenico
117 F. 99 · Court of Appeals for the Ninth Circuit · 1902
Facts
Libelants (fishermen) contracted with Alaska Packers' Association in San Francisco to work the fishing season in Pyramid Harbor, Alaska, for a set wage. Upon arrival in Alaska, the libelants stopped work and demanded a higher wage, threatening to return to San Francisco, despite having no valid reason for breach. The company's superintendent, unable to find replacements in the remote location, agreed to the increased pay, but stated he lacked authority to alter the original contract.
Issue
Was the subsequent agreement, made under duress, to pay the libelants an increased wage for performing services they were already contractually obligated to render, supported by sufficient consideration and thus enforceable?
Holding
The court held that the second agreement for increased wages was without consideration and therefore unenforceable. The judgment of the lower court, which had found for the libelants, was reversed.
Rule
A promise to pay a party for doing what they are already legally bound to do under an existing contract is without consideration and unenforceable. This principle, known as the pre-existing duty rule, prevents parties from extorting additional compensation by threatening to breach an existing obligation.
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